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By (November 1, 2008) No Comment

Pet Food Politics: The Chihuahua in the Coal Mine

By Marion Nestle
University of California Press, 2008

I had just started a new job at a large animal shelter last year when news of melamine-tainted pet food smacked the public in the face. Apart from fielding countless phone calls from worried pet owners and worrying about our own family pets, those of us on staff began to panic regarding the shelter’s food supply. Fortunately our food was not one of the affected brands, but we routinely used donated food of miscellaneous brands to supplement the standard diet if an animal was not eating or if our general supply was low. In the end, we were lucky and did not have any food-related deaths, but every morning for many weeks, I dreaded the possibility of walking in to a disaster.

The pet food recall certainly revealed the lack of communication within the animal care industry. As Marion Nestle points out in her new book Pet Food Politics, there is no veterinary-equivalent of the Centers for Disease Control (CDC). Despite being attached to a nationally renowned veterinary hospital, we in the shelter were getting all of our updates from CNN just like other pet owners across the country. There was no clear source of information—the FDA was inundated with phone calls while attempting to manage this public-relations nightmare—and answers eventually came from private researchers who found melamine and cyanuric acid (both nitrogen-rich industrial chemicals) in the foods, and journalists who traced the melamine back to China.

The recall encompassed nearly 200 brands of wet and dry dog and cat food in both the US and Canada. Although several other sources were eventually identified, everything began with a Canadian company named Menu Foods, which manufactured “cuts-and-gravy” style products for most of the large pet food companies. Menu recalled 60 million cans and foil pouches of pet food on March 16th and, over the course of the next four months, 17,000 pet illnesses or deaths would be reported to the FDA.

Pet Food Politics is Nestle’s heroic effort to create a linear narrative out of the mess that was the pet food recall of 2007. Despite multiple references to her own previous (and even forthcoming!) books, all dealing with issues surrounding the human food supply, this book is a very well-researched and straightforward description of the events surrounding what became the largest consumer product recall in US history.

Nestle takes the tone of a fearless investigative journalist, recounting off-the-record dinner conversations, government meetings, and corporate stonewalling. She doesn’t shy away from putting everything in context: not only does she cover several prior pet food recalls, but she even gives chemistry and history lessons on the fly. The book feels somewhat rushed, containing an incredible amount of information and analysis without a lot of style or editorializing. But Nestle efficiently accomplishes her goal: to demonstrate how the pet food recall affected everyone in the country, pet owner or not. The majority of Pet Food Politics details the actual recall and the parties involved, finishing up with a quick-and-dirty look at the recall’s impact on global trade policies, American consumer attitudes, governmental regulatory capabilities, and animal welfare.

Maybe it’s just the angry vegan in me that can’t help but wonder how things would have played out if it weren’t “just pet food” that was affected. The CDC would have stepped in and diagnostics would have been much more widespread, rather than just relegated to a handful of universities. Perhaps government investigation would have discovered the melamine during import or quality control checks, before it entered the food supply. Instead:

As explained by a spokesperson for the agency, Canada doesn’t regulate pet food: “We’re the Canadian Food Inspection Agency. We deal with food—and food is for humans.”

It is exactly this cavalier brand of oversight that lets tainted pet food enter the human food production system, as it did last year. As Nestle says, “Advocacy for policies good enough to protect pets also means advocacy for policies that protect people.”

Recalled pet food

Due to a remarkable amount of cooperation within the food industry, livestock farmers often purchase damaged (factory second) pet food to use in animal feed. Almost inevitably, some of the melamine-tainted stock was fed to hogs, chickens, and fish in various farms around the country. By the time of discovery, a large number of these animals had already made their way into the human food supply—the remaining animals were quarantined and tested or they were preemptively euthanized. The FDA asserted that “melamine…would be so diluted by the time it got to human food that its amount would be too low to be harmful.”

This would have made sense of course, if not for another unsettling discovery: an American feed company was also adding melamine to its products. The practice of adding melamine to livestock feed goes back some sixty years as a cheap way to increase nitrogen content. It also cheats the standard assay for measuring the amount of protein in the feed—making it the additive of choice for unscrupulous feed manufacturers.

A rather large amount of melamine is required to reach toxic levels: about 100 mg/kg causes a sheep to become ill, a slightly higher dose impairs renal function, and 250 mg/kg is fatal. The FDA claims that melamine doses up to 63 mg/kg are “safe,” albeit illegal. A confirmed number does not exist, but an estimated dose of melamine in the contaminated pet food is nearly 400 mg/kg.

Melamine is not specifically dangerous in incidental amounts. The complicating factor in the tainted pet food was cyanuric acid, which crystallizes in the presence of melamine under pH-neutral circumstances—such as within one’s kidneys.

The biggest unanswered question is: how many times did similarly tainted products enter the human food supply before last year? Nestle paints a grisly scenario:

Pet foods have always been made from the leftover parts of slaughtered farm animals that are not going to be used for human food—the bones, organs, ears, and other nutritious by-products. The need for an outlet for the leftovers of animal slaughter is one of the reasons commercial pet food exists. We now know the fate of salvaged pet food; it gets turned into feed for pigs, poultry, and farmed fish. I cannot resist having this unsettling thought: if federal officials had ordered the destruction of the pigs, chickens, and fish fed salvaged pet food, would their meat have been recycled back into pet food?

If, according to the FDA, dilution is the key factor in remaining safe, how many times can this cycle be repeated before we have a public health crisis?

Within the last year, consumer safety has increasingly been jeopardized. In China, lead and GHB (aka: the “date rape drug”) have tainted children’s toys, diethylene glycol found its way into toothpaste, oversulfated chondroitin sulfate was discovered in heparin, and melamine has reappeared recently in an array of milk products. Meanwhile, on the domestic front, the Humane Society broke the scandal of “downer” cows, and salmonella has affected peanut butter as well as a variety of produce.

This points to the ineffectiveness of governmental regulatory agencies. As Nestle explores, the food supply is regulated by two agencies: the USDA only oversees meat, while everything else falls under the jurisdiction of the FDA, which is merely one part of the Department of Health and Human Services:

Although this division of responsibility means that the FDA is responsible for the safety of 80% of the food supply, it gets only 20% of the federal budget for this purpose. In contrast, the USDA gets 80% of the budget for 20% of the foods.

And she’s so thorough that she even gives us a nice juicy piece of history:

The FDA is in trouble. It no longer has the capacity to protect the food supply. It still operates under food and drug laws passed in 1906 and modified in 1938, when the food supply was very different than it is today…. Robert Brackett, director of the Center for Food Safety and Applied Nutrition, explained his agency’s challenge…. “Globalization has changed the way the FDA has to function. The system was designed for whole foods brought in from a 50-mile radius. Now we have food products that may contain ingredients from 50 countries.”

The most groundbreaking effect of the pet food recall came about in November with this revolutionary legislation, not quoted by Nestle but available on the FDA’s website:

Although FDA has the authority to seize adulterated or misbranded food, this is not a practical option when contaminated product has already been distributed to hundreds or thousands of locations. And while the FDA has been able to accomplish most recalls through voluntary actions by product manufacturers or distributors, there are situations in which firms are unwilling to conduct a recall. In such situations FDA needs the ability to require a firm to conduct a recall to ensure the prompt and complete removal of food from distribution channels. This authority would be limited to foods that the Secretary has reason to believe are adulterated and present a threat of serious adverse health consequences or death. It would be imposed only if a firm refuses or unduly delays conducting a voluntary recall.

Yes, that’s right—the FDA was not authorized to issue a recall until 2007. Standard operating procedure for the last 69 years was to politely ask a company to issue a voluntary recall and hope for the best. Nestle demonstrates this process: shortly after the Menu Foods incident, jerky treats made in China for Wal-Mart were found to contain melamine yet the company merely removed the stock from its shelves rather than issue a recall.

Granted, it’s not good business practice to ignore a request for a recall. Globalization, in conjunction with unenforced Country of Origin Labeling (COOL) laws, makes it difficult to trace the source of every ingredient in a product, though. If a company denies any complicity in a suspected contamination, as happened with the individual pet food companies, precious time is wasted in finding the responsible party and even possible other affected products. Especially if the contaminated product is of low priority, such as pet food.

Nestle alludes to the ethical issue of the status of animals, but she remains fairly diplomatic and primarily refers to the suffering of poisoned pets and farm animals. She does not really need to climb on a PETA-issue soapbox and declare that we change our way of thinking about animals in this country—she has already provided all of the necessary evidence. The reader who is only inclined to think that this was an unfortunate series of events does not have to extrapolate any further; but the reader who feels outrage at the abuses permitted by ignorance and carelessness will understand that this points to something much larger than tainted food.

I will try to avoid climbing on my PETA-issue soapbox here, but perhaps if we, as humans, didn’t feel so entitled and actually respected the role animals play in our lives, we would be more conscious of animal welfare issues. Although animals in this country legally are mere property—either for personal or commercial use—our treatment of them affects our lives as well. Inhumane farm practices lead to unhealthy animals and unsanitary facilities, which result in contaminated food. Animal cruelty poses a public health hazard by potentially transmitting disease and encouraging violent tendencies. And an unquestioning lack of concern for dying pets can shake consumer confidence to its core:

The barking of this particular Chihuahua attracted worldwide attention and produced worldwide repercussions. We owe the dogs and cats involved in this episode a debt of gratitude

Sara Shaffer works at the aforementioned “nationally renowned veterinary hospital” in Boston, with the ultimate goal of going into massive debt (i.e., vet school).

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